Privacy Policy

Introduction & Identity of the Data Controller

aajl ("we," "us," "our," or "aajl") is a PAGCOR-licensed online gaming platform operating in the Philippines. In relation to the personal data of players, prospective players, and website visitors, aajl acts as the Data Controller within the meaning of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

This Privacy Policy applies to all personal data collected through the aajl website at aajl.asia, any aajl mobile application, and all related services, communications, and interactions with aajl. It governs how we handle your information from initial registration through to account closure.

By registering for an aajl account, making a deposit, or continuing to use the platform after this Policy has been brought to your attention, you acknowledge that you have read and understood its contents. If you do not agree with the processing activities described in this Policy, you should not create an aajl account or use the platform.

Personal Data We Collect

aajl collects personal data across several categories, each serving a specific and documented operational or regulatory purpose. The following table summarizes the categories of personal data we process:

How We Collect Your Data

aajl collects personal data through the following channels and mechanisms:

• Direct collection: When you register an aajl account, you provide your mobile number, name, date of birth, and other registration details directly. You also provide data when you update your profile, submit KYC documents, contact support, or use responsible gaming tools.
• Transaction processing: When you deposit or withdraw funds via GCash, PayMaya, BDO, BPI, Metrobank, or other payment channels, transaction details — including reference numbers, amounts, and timestamps — are collected and associated with your aajl account.
• Automated technical collection: aajl's servers automatically record technical data each time your device communicates with the platform, including IP addresses, device identifiers, and session timestamps. This occurs whether or not you are logged in to your account.
• Cookies and tracking technologies: aajl's website uses cookies and similar technologies. Details are provided in Section 7 of this Policy.
• Third-party sources: aajl may receive personal data about you from identity verification service providers, payment processors, fraud detection services, and — where legally required — government or regulatory bodies such as PAGCOR and the Anti-Money Laundering Council (AMLC).

aajl does not purchase personal data from data brokers or marketing list providers for the purpose of soliciting Philippine players. All data we hold on you originates from your own interaction with aajl or from regulated third-party verification and payment services engaged to operate the platform.

Purposes of Processing

aajl processes your personal data for the following documented purposes. Each purpose is supported by a legal basis as detailed in Section 5:

• Account registration and management: To create, maintain, and operate your aajl player account, including verification of your identity and age (21+ requirement), management of your wallet, and processing your gaming sessions.
• Payment processing: To process your deposits and withdrawals through GCash, PayMaya, BDO, BPI, Metrobank, InstaPay, PESONet, and other payment channels, and to maintain accurate financial records of all transactions.
• Identity and age verification (KYC): To verify that you meet the minimum age requirement (21+) as mandated by PAGCOR, and to satisfy Know Your Customer obligations under the Anti-Money Laundering Act (Republic Act No. 9160) as amended.
• Regulatory compliance and reporting: To fulfill aajl's obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and any other relevant Philippine government authority.
• Platform security and fraud prevention: To detect, investigate, and prevent fraudulent transactions, account abuse, cheating, collusion, money laundering, and other prohibited activities on the aajl platform.
• Responsible gaming: To operate aajl's responsible gaming program, including administering self-exclusions, deposit limits, session controls, and identifying players who may be exhibiting signs of problem gambling.
• Customer support: To respond to your enquiries, resolve disputes, process complaints, and deliver assistance related to your aajl account.
• Platform improvement: To analyze aggregate, anonymized usage patterns that help aajl improve platform performance, game selection, and user experience for Filipino players.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where aajl has a legitimate interest in communicating with existing players. You may opt out at any time.

Legal Bases for Processing

Under the Data Privacy Act of 2012, aajl must identify a lawful basis for each category of personal data processing. The primary legal bases on which aajl relies are:

• Contractual necessity: Processing your registration data, financial data, and gaming activity data is necessary to perform the contract between you and aajl (i.e., to operate your account and provide the gaming services you have requested).
• Legal obligation: Processing for KYC, AMLC reporting, PAGCOR regulatory compliance, and age verification is necessary for aajl to comply with applicable Philippine law. This processing cannot be opted out of — it is a condition of account maintenance.
• Legitimate interests: Processing for fraud detection, platform security, responsible gaming identification, and aggregate analytics is carried out on the basis of aajl's legitimate interests in maintaining a safe, fair, and sustainable gaming environment, provided these interests do not override your rights and freedoms.
• Consent: Processing for direct marketing communications beyond the scope of your contractual relationship with aajl is carried out on the basis of your consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Data Sharing & Disclosure

aajl does not sell your personal data. We share personal data only in the circumstances and with the categories of recipients described below:

• Payment service providers: GCash (GXI), PayMaya (Maya Bank), BDO Unibank, Bank of the Philippine Islands (BPI), Metrobank, and other payment processors receive transactional data strictly necessary to execute your deposit and withdrawal requests.
• Identity verification providers: Third-party KYC and identity verification services engaged by aajl receive the personal and identity documents you submit, solely for the purpose of verifying your identity and age.
• Game providers: Game studios and content providers whose games appear in the aajl lobby may receive anonymized session data for technical integration purposes. Where identifiable data is shared, it is governed by data processing agreements.
• Regulatory and government authorities: PAGCOR, AMLC, the NPC, law enforcement agencies, and courts may receive personal data from aajl where disclosure is required by applicable Philippine law, regulation, court order, or to prevent, detect, or investigate illegal activity.
• IT and infrastructure providers: Cloud hosting, platform infrastructure, and cybersecurity service providers who process data on aajl's behalf under binding data processing agreements with equivalent data protection obligations.
• Professional advisers: Lawyers, auditors, and other professional advisers who require access to personal data to provide services to aajl, subject to professional confidentiality obligations.

Cookies & Tracking Technologies

aajl uses cookies and similar technologies on the aajl.asia website and platform. A cookie is a small text file placed on your device by a website. Cookies help the platform function correctly, remember your preferences, and provide analytics data that helps aajl improve the player experience.

aajl uses the following categories of cookies:

• Strictly necessary cookies: These cookies are essential for the aajl platform to function. They enable core features such as session management, login authentication, and security tokens. These cannot be disabled without impairing platform functionality.
• Performance and analytics cookies: These cookies collect anonymized data about how players use the aajl platform — which pages are visited most frequently, where errors occur, and how players navigate between sections. This data helps aajl improve platform performance and user experience.
• Functionality cookies: These cookies remember your preferences — such as language settings and recently played games — to provide a more personalized experience on aajl.
• Marketing and targeting cookies: Where you have provided consent, these cookies may be used to deliver relevant promotional content within the aajl platform. They do not transmit your data to third-party advertising networks.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the aajl platform, including logging in to your account.

Data Retention

aajl retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the minimum and maximum retention periods imposed by applicable Philippine law and PAGCOR regulatory requirements. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account plus a minimum of five (5) years following account closure, as required under the Anti-Money Laundering Act and PAGCOR obligations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLC requirements and applicable tax regulations.
• Gaming activity data: Retained for a minimum of five (5) years from the date of each gaming session, as required by PAGCOR regulatory reporting obligations.
• Customer support communications: Retained for three (3) years from the date of the last interaction, or longer if the communication is relevant to an ongoing dispute, regulatory investigation, or legal proceeding.
• Marketing consent records: Retained for the duration of your consent plus three (3) years, to provide evidence of your consent in the event of a complaint to the NPC or aajl.
• Technical and session data: Typically retained for twelve (12) months in accessible form, with longer retention in anonymized aggregate form for analytics purposes.

Upon expiry of the applicable retention period, aajl will securely delete or anonymize the relevant personal data. Where technical constraints prevent immediate deletion, aajl will implement access restrictions to prevent the data from being processed for any purpose other than eventual deletion.

Security Measures

aajl implements technical and organizational measures designed to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures are proportionate to the sensitivity of the data being protected and include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and aajl servers.
• Encryption of sensitive data at rest, including financial data and KYC documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Two-factor authentication for aajl staff accessing systems that contain personal data.
• Regular penetration testing and vulnerability assessments conducted by independent security professionals.
• Automated fraud detection systems monitoring transactions and login activity in real time.
• Regular staff training on data protection and cybersecurity obligations.
• Incident response procedures and a dedicated data breach notification protocol compliant with the NPC's requirements.

Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by aajl. To exercise any of these rights, contact aajl's Data Protection Officer using the details in Section 15.

aajl may be required to verify your identity before processing a data subject request. This is to protect your data from unauthorized access requests. Identity verification for this purpose does not involve any additional collection of data beyond what is already held on your account.

Children's Privacy

The aajl platform is strictly intended for individuals aged twenty-one (21) years and above, as mandated by PAGCOR regulations governing online casino gaming in the Philippines. aajl does not knowingly collect, process, or retain personal data from individuals under the age of 21.

All account registrations require confirmation of age eligibility, and aajl implements KYC verification procedures to detect and prevent underage registration. If aajl discovers that personal data has been collected from a person under the age of 21 — whether through direct registration, third-party account access, or other means — aajl will immediately:

• Suspend and permanently close the affected account.
• Reverse any deposits and forfeit any winnings accumulated during the period of underage access, in accordance with PAGCOR regulatory requirements.
• Delete all personal data associated with the underage individual to the extent not required for regulatory reporting purposes.
• Report the incident to PAGCOR where required by applicable regulations.

Cross-Border Data Transfers

The aajl platform is operated primarily within the Philippines. However, some of the third-party service providers engaged by aajl — including cloud hosting providers, KYC verification services, and game studios — may process personal data outside the Philippines.

Where personal data is transferred outside the Philippines, aajl ensures that appropriate safeguards are in place in accordance with the Data Privacy Act of 2012 and NPC regulations. These safeguards may include:

• Data Processing Agreements incorporating standard contractual clauses approved by or consistent with NPC guidance.
• Transfers to countries or organizations that have been determined to offer an adequate level of data protection.
• Binding Corporate Rules where applicable within aajl's group of affiliated entities.

aajl does not transfer personal data outside the Philippines to countries or jurisdictions that do not offer adequate data protection safeguards, unless such transfer is required by Philippine law or PAGCOR regulatory obligation, or unless you have provided your explicit consent to such transfer.

Third-Party Links & Services

The aajl platform may contain references to third-party services, including game providers, payment processing services, and banking partners. Where you interact directly with a third-party service — such as authorizing a GCash payment through the GCash application — you are subject to that third party's own privacy policy and terms of service, over which aajl has no control.

aajl is not responsible for the privacy practices of third-party services, regardless of whether those services are accessed through or in connection with the aajl platform. We encourage you to review the privacy policies of any third-party service you interact with, including GCash, PayMaya, your bank's online portal, and any game studio whose games you play on aajl.

Policy Amendments

aajl reserves the right to update this Privacy Policy at any time. The most current version of the Policy, with the effective date displayed prominently, will always be available on the aajl.asia website. Where changes are material — meaning they significantly affect how your personal data is processed or your rights in relation to it — aajl will provide advance notice via:

• A prominent notification on the aajl platform for logged-in users.
• An SMS notification to your registered Philippine mobile number, where technically feasible.
• An email to your registered email address if one is held on your account.

Continued use of the aajl platform following the effective date of any Policy amendment constitutes acceptance of the updated Privacy Policy. If you do not accept the amended Policy, you should cease using the platform and contact aajl support to close your account. Your data subject rights are not affected by any Policy amendment.

Contact & Complaints

If you have questions about this Privacy Policy, wish to exercise a data subject right, or wish to raise a privacy concern or complaint regarding aajl's data processing practices, please contact us through the following channels:

aajl will acknowledge all data subject requests within seventy-two (72) hours of receipt and provide a substantive response within thirty (30) calendar days. Complex requests may require additional time — aajl will notify you if an extension is necessary, with an explanation of the reason for the delay.

If you are not satisfied with aajl's response to your privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the independent regulatory body responsible for enforcing the Data Privacy Act of 2012. Information on how to file a complaint with the NPC is available through the NPC's official government website.